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Are non-registered healthcare professionals who wish to use the title “Dr” on their business cards required to state their doctorate / PhD qualifications and include the relevant disclaimers?
The Healthcare Services Act 2020 (HCSA) FAQs, Enhanced advertising control of healthcare service
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If the business cards are used to promote a healthcare service, these business cards would be considered as healthcare service advertising, and the requirements under the advertising controls must then be complied with (e.g., on mandatory disclosure of qualifications).
For example, if the business card set out the healthcare services that a nonregistered healthcare professional provides e.g. osteopath services, it would be considered as an advertisement of a healthcare service. Hence, the following requirements apply:
state the educational qualifications whenever the title “Dr” is used; and
include a disclaimer that the educational qualification is not a medical or dental qualification
However, if the information in the business cards is unrelated to healthcare services, the requirements of mandatory disclosure of qualifications and disclaimer would not apply.
For example, if the business card contained information such as the name of the business entity, its address and website, the name of the non-registered healthcare professional, qualifications, email address and associations of which the non-registered healthcare professional is a member, it would not be an advertisement of a healthcare service and is not subject to the requirements set out above.
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